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Member Data Commercial Usage

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Dear The Financial Conduct Authority,

Can you provide the details of which commercial enterprises are given access and license to resell member data and how much these organisations pay to access this data.

Yours faithfully,

Darren Isaac

The Financial Conduct Authority

Thank you for e-mailing the Financial Conduct Authority's Information Access Team. This is an automatic acknowledgement to tell you we have received your email safely. Please do not reply to this email. We will be in touch in due course.

This communication and any attachments may contain personal information. For more information about how and why we use personal information and who to contact with any queries about this, please see our privacy notices: FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice (https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is confidential and may be subject to legal privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute, publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential information which it could be a criminal offence for you to disclose or use without authority. If you have received this email in error please notify [email address] immediately and delete the email from your computer. Further information on the classification and handling of FCA information can be found on the FCA website (http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all email communications for compliance with legal, regulatory and professional standards.

This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.

The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623. Registered office: 25 The North Colonnade, Canary Wharf, London E14 5HS, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864. Registered office: 25 The North Colonnade, Canary Wharf, London E14 5HS, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)

Freedom of Information, The Financial Conduct Authority

1 Attachment

Our Ref: FOI6487

 

Dear Mr Isaac,

 

Freedom of Information: Right to know request

 

Thank you for your request for information under the Freedom of
Information Act 2000 (the Act) made on 22 May 2019, for the following
information:

 

“details of which commercial enterprises are given access and license to
resell member data and how much these organisations pay to access this
data”.

 

We regret to inform you that we are unable to process your request because
it is insufficiently clear.

For us to process your request could you please therefore clarify the
following:

 

•        You referred to ‘member data’. Please can you clarify what data
you are referring to and what membership(s)?

•        You also refer to commercial enterprises being given access to
licenses and reselling member data. To what persons or entities granting
access or licences are you referring?

 

Please can you also specify if the information you are seeking is at the
time of your request (i.e when the request was received by the FCA) or if
not please specify a period.

 

We will be unable to proceed with your request without clarification of
the information you wish to receive.

 

Please note that under guidance issued by the Ministry of Justice and the
Information Commissioner's Office entitled "Freedom of Information &
Environmental Information Regulations - Hints for practitioners handling
FOI/EIR requests", the following advice has been given with regard to the
clarification of requests:

 

"The day after the clarification is received by the public authority the
20 working day period begins" (page 14).

 

We have attached the link to the Guidance for your information:

 

https://www.gov.uk/government/publicatio...

 

The 20 working day period will therefore commence once we have received
sufficient clarification to allow us to deal with your request.

 

If we do not receive a response within 40 working days from the date of
this letter we shall assume that you no longer wish to pursue your enquiry
and will therefore close your request. In such an event, you would need to
submit a new Freedom of Information request for any information you wish
to receive.

 

If you have any queries please contact us.

 

Yours sincerely,

 

Information Disclosure Team / Cyber & Information Resillience Department

[1]Description: cid:image001.png@01D2A7C9.64DDD390

 

Financial Conduct Authority

12 Endeavour Square

London

E20 IJN

 

 

 

 

 

 

 

 

 

 

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

References

Visible links

Dear Sir/Madam,

Thank you for your reply.

• You referred to ‘member data’. Please can you clarify what data
you are referring to and what membership(s)?

I am seeking a list of all your registered (member) insurance brokers in the form of the company name, contact email address, postal and telephone contact information.

• You also refer to commercial enterprises being given access to
licenses and reselling member data. To what persons or entities granting
access or licences are you referring?

I am aware of at least one commercial enterprise that is reselling the data I am requesting and I understand this to be on behalf of, or under license from, the FCA. In fact, I have an email from the FCA referring me to this company. For this reason, we would like to clarify what commercial relationships exist, and with which companies, for the right to access and resell this data. We have raised this point because a previous request for this data was denied on the basis "providing this data is too difficult" and we have proof that is simply not the case.

My primary objective here is simply to be provided with the above data. My secondary objective is to understand, especially if there is a problem with this request, details of which companies the FCA has a commercial agreement with to supply this data.

Yours sincerely,

Darren Isaac

The Financial Conduct Authority

Thank you for e-mailing the Financial Conduct Authority's Information Access Team. This is an automatic acknowledgement to tell you we have received your email safely. Please do not reply to this email. We will be in touch in due course.

This communication and any attachments may contain personal information. For more information about how and why we use personal information and who to contact with any queries about this, please see our privacy notices: FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice (https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is confidential and may be subject to legal privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute, publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential information which it could be a criminal offence for you to disclose or use without authority. If you have received this email in error please notify [email address] immediately and delete the email from your computer. Further information on the classification and handling of FCA information can be found on the FCA website (http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all email communications for compliance with legal, regulatory and professional standards.

This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.

The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623. Registered office: 25 The North Colonnade, Canary Wharf, London E14 5HS, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864. Registered office: 25 The North Colonnade, Canary Wharf, London E14 5HS, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)

Freedom of Information, The Financial Conduct Authority

 

Our ref:  FOI6487

 

 

Dear Mr Isaac

 

We refer to your request under the Freedom of Information Act 2000 (“the
Act”) for the following information:

 

“Can you provide the details of which commercial enterprises are given
access and license to resell member data and how much these organisations
pay to access this data.”

 

Your request is currently being considered and, in doing so, we are of the
view that the qualified exemption at section 43 (commercial interests) of
the Act may apply.  This is because we consider that disclosure would, or
would be likely to, prejudice the commercial interests of any person
(including the public authority holding it).

 

As this is the case, the FCA is required to weigh the public interest in
maintaining the exemption against the public interest in disclosing any
information.

 

By virtue of section 10(3), where public authorities have to consider the
balance of the public interest in relation to a request, they do not have
to comply with the request until such time as is reasonable in the
circumstances.  The FCA has not yet reached a decision on the balance of
the public interest.

 

Due to the need to consider, in all the circumstances of the case, where
the balance of the public interest lies in relation to the information
that you have requested, the FCA will not be able to respond to your
request in full within 20 working days.  In these circumstances, we hope
to be in a position to respond to you by 2 August 2019, although should we
be in a position to contact you sooner we will do so.

 

Yours sincerely

 

 

Information Disclosure Team

Financial Conduct Authority

 

 

 

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

Dear Information Disclosure Team,

I note your comments and await your further response.

I wish to state for the record that there are two aspects to my freedom of information request. The first is that the contact information for all registered insurance brokers be provided (address, telephone, email).

The second is that I know this public information IS being sold privately, presumably under license from the FCA. I have evidence of this as my company has bought some of it and I am therefore aware of one company doing this as the FCA referred me to them. I will save you the trouble of considering whether to give their name and state publicly that it is Autus Data Services. I wish to know if there are others or if this is an exclusive arrangement with Autus Data Services?

Please could you kindly answer both of these questions as, you can clearly see, I want to know if I can have access to this information which I believe the public has a right to, or if there is a problem due to commercial interests being involved.

Yours sincerely,

Darren Isaac

The Financial Conduct Authority

Thank you for e-mailing the Financial Conduct Authority's Information Access Team. This is an automatic acknowledgement to tell you we have received your email safely. Please do not reply to this email. We will be in touch in due course.

This communication and any attachments may contain personal information. For more information about how and why we use personal information and who to contact with any queries about this, please see our privacy notices: FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice (https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is confidential and may be subject to legal privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute, publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential information which it could be a criminal offence for you to disclose or use without authority. If you have received this email in error please notify [email address] immediately and delete the email from your computer. Further information on the classification and handling of FCA information can be found on the FCA website (http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all email communications for compliance with legal, regulatory and professional standards.

This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.

The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623. Registered office: 25 The North Colonnade, Canary Wharf, London E14 5HS, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864. Registered office: 25 The North Colonnade, Canary Wharf, London E14 5HS, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)

Freedom of Information, The Financial Conduct Authority

Our ref: FOI6487

Dear Mr Isaac

Thank you for your email.

We can confirm that we are considering both aspects of your request and will respond to you by the deadline stated in our email below.

Yours sincerely

Information Disclosure Team
Financial Conduct Authority

show quoted sections

Freedom of Information, The Financial Conduct Authority

 

Our ref:  FOI6487

 

 

Dear Mr Isaac

 

We refer to your request of 22 May 2019 under the Freedom of Information
Act 2000 (“the Act”) for the following information:

 

“Can you provide the details of which commercial enterprises are given
access and license to resell member data and how much these organisations
pay to access this data.”

 

On 7 June 2019 you clarified that by “member data”, you were seeking a
list of all FCA registered (member) insurance brokers in the form of the
company name, contact email address, postal and telephone contact
information.

 

Secondly, where you refer to “commercial enterprises”, you clarified that
you are aware of at least one commercial enterprise that is reselling the
data you are requesting, which you understand this to be on behalf of, or
under license from, the FCA, and would like to clarify what commercial
relationships exist, and with which companies, for the right to access and
resell this data.

 

Your request has been considered and we will deal with each of the above
aspects in turn.

 

The first part relating to “member data” follows from a previous request
submitted on 19 Aril 2019 for the following information:

 

“Could you please provide the names, addresses, telephone numbers and
email addresses for all registered general insurance brokers, as a matter
of public record.”

 

We responded on 22 May 2019 (under reference FOI6409) citing the cost
limit exemption as we were of the view that it would take far in excess of
18 hours to process your request.  The reason for this is because there is
no regulatory definition for a ‘general insurance broker’;  rather there
is a suite of permissions that brokers would use but that other authorised
firms would also use (for example, a motor dealer may use these
permissions but would not be considered a ‘broker’).

 

Therefore, as explained to you in our email of 22 May, we would need to
manually review the profiles of approximately 6,500 firms to establish
which were ‘general insurance brokers’.  Although you requested an
internal review of our decision to reject your request on the grounds of
cost, we are dealing with this aspect in this first stage response as
well.  This is because, when we responded to you on 22 May, we explained
that we could consider a refined request for a list of firms with
permissions that allow them to carry out general insurance broking and
that are supervised within our General Insurance Portfolios.  However,
please be aware that not all firms listed will necessarily be general
insurance brokers or be carrying out that activity.  If you still wish us
to consider this refined request, please let us know.

 

Turning now to your request submitted on 22 May 2019 relating to the
“commercial enterprises” who have been “given access and license to resell
member data and how much these organisations pay to access this data”, we
wrote to you on 5 July 2019 and advised that we needed additional time to
consider your request.  This is because we considered that section 43
(Commercial interests) may apply to some (or all) of the information and a
decision had not yet been reached on the balance of public interest in
respect of that information.

 

This exercise has now been completed.  We are unable to provide you with
the names of the firms concerned as the fact that they have entered into
an agreement with the FCA to provide this service, has been done in
confidence.  Therefore we consider that section 41 (Information provided
in confidence) of the Act applies.  In addition, we consider that section
43 (Commercial interests) of the Act applies as disclosure of the names
would, or would be likely to, prejudice the commercial interests of any
person (including the public authority holding it).

 

For a detailed explanation of why these exemptions apply, please refer to
Annex A below.

 

Notwithstanding the above, you may be aware that the FCA is partnered with
Spectrum Data Management (SDM) who provide an online Register Extract
download service and interrogation facilities for the data.  Further
details can be found on our website [1]here.  This page also outlines the
charges made to firms for this service.

 

When using this service, information is sent to purchasers about the firms
/ individuals on our register either for single copies, weekly updates, or
monthly updates.  Purchasers should indicate on the Extract Service
Subscription Order Form how the information is to be used, i.e. for either
'Other: own business' (marketing), 'FCA/PRA Compliance: own business'
(compliance), or 'Commercial Re-use' purposes (reselling the data to other
parties).

 

Finally, you may wish to be aware that a copy of the Register Extract is
now provided by the FCA to the British Library on CD each month.  It is
available from them free of charge and the following information (provided
by the British Library) should help you to find the copies they keep:

 

Shelf mark:  HMNTSEC.9X1072

Bibliographic number:  18856591

 

Should you wish to make use of this service, you should bear in mind that
the extract is only provided to them on a monthly basis and may therefore
not be up to date at the time of your request.

 

If you are unhappy with the decision made in relation to your request, you
have the right to request an internal review. If you wish to exercise this
right you should contact the Information Disclosure Team within 40 working
days of the date of this response.

 

If you are not content with the outcome of the internal review, you also
have a right of appeal to the Information Commissioner at Information
Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9
5AF.  Telephone: 01625 545 700.  Website: [2]www.ico.org.uk

 

Yours sincerely

 

 

Information Disclosure Team

Financial Conduct Authority

 

 

Annex A

 

·                Section 41:  Information provided in confidence

 

Section 41 of the Act provides that "Information is exempt information if:

 

a)     it was obtained by the public authority from any other person
(including another public authority),  and

 

b)     the disclosure of the information to the public (otherwise than
under this Act) by the public authority holding it would constitute a
breach of confidence actionable by that or any other person.”

 

The fact that these particular firms have subscribed to this service and
entered into an agreement with the FCA, is information that has been
provided to the FCA in confidence.  We therefore consider that disclosure
would constitute an actionable breach of confidence.  In coming to this
conclusion, we have taken the view that the names of the firms should be
withheld as the public interest in disclosure does not outweigh the public
interest in maintaining the confidence.

 

Section 41 is an absolute exemption and not itself subject to the public
interest test under the Act.

 

·                     Section 43 (Commercial Interests)

 

Section 43(2) of the Act provides that information is exempt if its
disclosure would, or would be likely to, prejudice the commercial
interests of any person (including the public authority holding it).

 

The commercial interests of the firms in question may be harmed in several
ways as disclosure of the information would be likely to lead to further
comment and speculation about them.  This, in turn, would or would be
likely to harm the firms’ brand and so harm their commercial interests as
well as that of their stakeholders, including their employees.  As there
is no routine public disclosure of firms’ dealings with the FCA, ad hoc
public disclosure under the Act would be likely to attract a
disproportionate amount of attention to the firms concerned.

 

This exemption is qualified and we have balanced the public interest for
and against disclosure as required by the Act.

 

For disclosure:

 

·                Disclosure of the information would reassure the public
about the effectiveness of the regulatory approach taken by the FCA, and
demonstrate how the FCA responds to supervisory matters within the sector
it regulates.

 

·                Disclosure would also provide information to consumers to
assist them in making decisions about their dealings or potential dealings
with firms and individuals that are, or may be, operating in the financial
services industry.

 

Against disclosure:

 

·                As explained above, disclosure of the information could
lead to widespread speculation about the firms which, in turn, could
affect their brand and reputation in the market in which they operate, in
the absence of due process having been followed - i.e. in the absence of
any formal public announcement and without the firms having had the
opportunity to comment.

 

·                It is strongly in the public interest that the FCA has
open and candid exchanges of information with the firms it enters into a
commercial agreement with, regardless of the commercial sensitivity of the
information.

 

On this occasion, and for the reasons set out above, we have concluded
that the balance of the public interest is in favour of not disclosing the
information.

 

 

 

 

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

References

Visible links
1. https://www.fca.org.uk/firms/financial-s...
2. http://www.ico.org.uk/

Dear FCA,

Thank you for your substantive response.

Please could you provide the contact information (name, address, phone, email, website) you hold for all registered insurance brokers of any kind or, if that is not possible, all registered insurance members, or all members, including their financial services categories.
Thank you.

Yours sincerely,

Darren Isaac

The Financial Conduct Authority

Thank you for e-mailing the Financial Conduct Authority's Information Access Team. This is an automatic acknowledgement to tell you we have received your email safely. Please do not reply to this email. We will be in touch in due course.

This communication and any attachments may contain personal information. For more information about how and why we use personal information and who to contact with any queries about this, please see our privacy notices: FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice (https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is confidential and may be subject to legal privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute, publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential information which it could be a criminal offence for you to disclose or use without authority. If you have received this email in error please notify [email address] immediately and delete the email from your computer. Further information on the classification and handling of FCA information can be found on the FCA website (http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all email communications for compliance with legal, regulatory and professional standards.

This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.

The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623. Registered office: 25 The North Colonnade, Canary Wharf, London E14 5HS, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864. Registered office: 25 The North Colonnade, Canary Wharf, London E14 5HS, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)

Freedom of Information, The Financial Conduct Authority

1 Attachment

Our Ref: FOI6689

Dear Mr Isaac


Freedom of Information: Right to know request

Thank you for your request under the Freedom of Information Act 2000 (“the Act”) dated 01 August 2019 for the following information;

“Please could you provide the contact information (name, address, phone, email, website) you hold for all registered insurance brokers of any kind or, if that is not possible, all registered insurance members, or all members, including their financial services categories.”

Your request has now been considered and our response is set out below.

When we responded to you on 22 May, we explained that we could consider a refined request for a list of firms with permissions that allow them to carry out general insurance broking and that are supervised within our General Insurance Portfolios.
Please find this list of all registered brokers by portfolio in Annex A.

Kindly note, as previously explained, not all the firms listed will necessarily be general insurance brokers or be carrying out that activity.

If you are unhappy with the decision made in relation to your request, you have the right to request an internal review. If you wish to exercise this right you should contact us within 40 working days of the date of this response.

If you are not content with the outcome of the internal review, you also have a right of appeal to the Information Commissioner at: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone: 01625 545 700. Website: www.ico.org.uk

Yours sincerely

Information Disclosure Team

This communication and any attachments may contain personal information. For more information about how and why we use personal information and who to contact with any queries about this, please see our privacy notices: FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice (https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is confidential and may be subject to legal privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute, publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential information which it could be a criminal offence for you to disclose or use without authority. If you have received this email in error please notify [email address] immediately and delete the email from your computer. Further information on the classification and handling of FCA information can be found on the FCA website (http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all email communications for compliance with legal, regulatory and professional standards.

This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.

The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623. Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864. Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)

Dear The Financial Conduct Authority,

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of The Financial Conduct Authority's handling of my FOI request 'Member Data Commercial Usage'.

Whilst some of the information has been supplied, I have explicitly requested the email addresses. The data provided shows they are stored but have been redacted from what I have been supplied.

Can you please supply the email addresses and not a redaction or, at this point, it will have to become a matter for the Information Commissioner as to why this information is being purposely withheld.

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/m...

Yours faithfully,

Darren Isaac

The Financial Conduct Authority

Thank you for e-mailing the Financial Conduct Authority's Information Access Team. This is an automatic acknowledgement to tell you we have received your email safely. Please do not reply to this email. We will be in touch in due course.

This communication and any attachments may contain personal information. For more information about how and why we use personal information and who to contact with any queries about this, please see our privacy notices: FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice (https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is confidential and may be subject to legal privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute, publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential information which it could be a criminal offence for you to disclose or use without authority. If you have received this email in error please notify [email address] immediately and delete the email from your computer. Further information on the classification and handling of FCA information can be found on the FCA website (http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all email communications for compliance with legal, regulatory and professional standards.

This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.

The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623. Registered office: 25 The North Colonnade, Canary Wharf, London E14 5HS, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864. Registered office: 25 The North Colonnade, Canary Wharf, London E14 5HS, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)

Dear The Financial Conduct Authority,

This matter is now unacceptably overdue and falls extensively outside of the ICO's guidelines. Given that the information sent to me appeared to have the email addresses purposely redacted, with no reason given for this, I now have no choice but to file this wilful attempt not to provide data to the ICO.

Unless the data I requested is received in its unredacted form (including email addresses) within 14 days, I will be taking my complaint to the ICO.

Yours faithfully,

Darren Isaac

The Financial Conduct Authority

Thank you for e-mailing the Financial Conduct Authority's Information Access Team. This is an automatic acknowledgement to tell you we have received your email safely. Please do not reply to this email. We will be in touch in due course.

This communication and any attachments may contain personal information. For more information about how and why we use personal information and who to contact with any queries about this, please see our privacy notices: FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice (https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is confidential and may be subject to legal privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute, publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential information which it could be a criminal offence for you to disclose or use without authority. If you have received this email in error please notify [email address] immediately and delete the email from your computer. Further information on the classification and handling of FCA information can be found on the FCA website (http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all email communications for compliance with legal, regulatory and professional standards.

This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.

The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623. Registered office: 25 The North Colonnade, Canary Wharf, London E14 5HS, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864. Registered office: 25 The North Colonnade, Canary Wharf, London E14 5HS, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)

Freedom of Information, The Financial Conduct Authority

1 Attachment

Our Ref: FOI6689

 

 

Dear Mr Isaac

 

Freedom of Information: Right to know request

 

We refer to your email of 18 October 2019 following our response to you
under the Freedom of Information Act 2000 (“the Act”) under reference
FOI6689.

 

You requested an internal review of our response as you were of the view
that “information was being purposely withheld”.  This was because the
list of firms we provided to you did not all contain a contact email
address.

 

We have liaised with the relevant business area and can confirm that, due
to the way in which the data was extracted in order to respond to your
request, some of the email addresses were not captured.  However, you may
wish to be aware that, where provided by the firm, email addresses are
publicly available on the FS Register under each firm’s contact details. 
They can therefore be searched using the list we provided to you.

 

Yours sincerely

 

Information Disclosure Team

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

To Whom it May Concern,

Please pass this on to the most senior person responsible for compliance with Freedom of Information requests.

Take notice of a 14-day deadline before I complain to the ICO. This is final opportunity I am giving the FCA to fulfil my request and, if there is any data missing, I will be raising a complaint with the ICO on the basis I believe very strongly it is being purposely withheld. My request has been ongoing for substantially outside the ICO's FOI guidelines and is now fully within the territory of it being a punishable offence.

I am writing to request an internal review of The Financial Conduct Authority's handling of my FOI request 'Member Data Commercial Usage'.

I have asked repeatedly for the supply of email data on registered insurance members. This is a very simple, specific and clear request. I have been supplied only redacted information with no email addresses provided or told that there was a mistake/issue pulling the data with no remedy suggested. I simply do not accept this is the case and insist, one final time, I be supplied with the full list requested including all email addresses. The last correspondence claimed "some email addresses" were not be pulled through, implying it was an error, but there were in fact NO email addresses. This is therefore either down to incompetence, or wilful omission and I do not accept that this satisfies my request.

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/m...

Again, if the full list of data is not supplied within the next 14 days, I will be raising a serious, formal complaint with the Information Commissioner.

Yours faithfully,

Darren Isaac

The Financial Conduct Authority

Thank you for e-mailing the Financial Conduct Authority's Information Access Team. This is an automatic acknowledgement to tell you we have received your email safely. Please do not reply to this email. We will be in touch in due course.

This communication and any attachments may contain personal information. For more information about how and why we use personal information and who to contact with any queries about this, please see our privacy notices: FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice (https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is confidential and may be subject to legal privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute, publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential information which it could be a criminal offence for you to disclose or use without authority. If you have received this email in error please notify [email address] immediately and delete the email from your computer. Further information on the classification and handling of FCA information can be found on the FCA website (http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all email communications for compliance with legal, regulatory and professional standards.

This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.

The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623. Registered office: 25 The North Colonnade, Canary Wharf, London E14 5HS, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864. Registered office: 25 The North Colonnade, Canary Wharf, London E14 5HS, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment Systems Regulator Limited)

Freedom of Information Appeals, The Financial Conduct Authority

3 Attachments

Our Ref: FOI6689

 

Dear Mr Isaac

 

Freedom of Information: Right to know request

 

Thank you for your email dated 5 November 2019, regarding the information
you have requested under the Freedom of Information Act 2000 with the
above reference.  

 

We are considering the points you have raised and will contact you again
as soon as possible.  If it is likely to take more than 20 working days
from the date of receiving your email to respond in full, we will write to
you again.

 

Yours sincerely

 

 

Information Disclosure Team / Cyber and Information Resilience Department
/ Operations

[1]Description: cid:image001.png@01D2A7C9.64DDD390

12 Endeavour Square

London

E20 1JN

 

Tel:    +44 (0)20 7066 1000

[2]www.fca.org.uk

 

Follow us:

 

[3]Description: https://g.twimg.com/Twitter_logo_blue.pn...
image003

 

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

References

Visible links
2. http://www.fca.org.uk/
3. https://twitter.com/TheFCA
4. https://www.linkedin.com/company/financi...

Freedom of Information Appeals, The Financial Conduct Authority

3 Attachments

Our Ref: FOI6689

 

Dear Mr Isaac

 

Freedom of Information: Right to know request

 

I refer to my email dated 22 November 2019.  I am writing to inform you
that we have not yet reached a decision regarding your request for an
internal review of the FCA’s response to your information request with the
above reference, made under the Freedom of Information Act 2000.

 

We are still considering this matter and hope to be in a position to
respond to you by Monday 30 December 2019, although should we be able to
contact you sooner we will do so.

 

Thanking you for your patience.

 

Yours sincerely

 

Information Disclosure Team / Cyber and Information Resilience Department
/ Operations

[1]Description: cid:image001.png@01D2A7C9.64DDD390

12 Endeavour Square

London

E20 1JN

 

Tel:    +44 (0)20 7066 1000

[2]www.fca.org.uk

 

Follow us:

 

[3]Description: https://g.twimg.com/Twitter_logo_blue.pn...
image003

 

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

References

Visible links
2. http://www.fca.org.uk/
3. https://twitter.com/TheFCA
4. https://www.linkedin.com/company/financi...

Dear Sirs,

This has been continuing for some months and is now not just outside of the ICO requirement, it is substantially in excess of them – to the point of being wilfully obstructive.

Unfortunately, this is nowhere near good enough.

I am prepared to hold off for another 7 days only, so Thursday, 12th December. If the email data has not been provided by then, take formal notice I will be opening my complaint with the ICO and there will not be further notice of this.

Yours sincerely,

Darren Isaac

Freedom of Information Appeals, The Financial Conduct Authority

3 Attachments

Our Ref: FOI6689

 

Dear Mr Isaac

 

Freedom of Information: Right to know request

 

Thank you for your email of 5 December 2019. I am sorry to inform you that
we are still processing your request for information and therefore have
been unable to answer it fully by the deadline.

 

It is unfortunately not possible for us to respond to you by Thursday 12
December 2019. This is because we are currently experiencing a very high
volume of incoming requests. We will endeavour to send you a response by
Monday 30 December 2019, although should we be able to contact you sooner
we will do so.

 

In the meantime, I thank you for your understanding and patience.

 

Yours sincerely

 

Information Disclosure Team / Cyber and Information Resilience Department
/ Operations

[1]Description: cid:image001.png@01D2A7C9.64DDD390

12 Endeavour Square

London

E20 1JN

 

Tel:    +44 (0)20 7066 1000

[2]www.fca.org.uk

 

Follow us:

 

[3]Description: https://g.twimg.com/Twitter_logo_blue.pn...
image003

 

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

References

Visible links
2. http://www.fca.org.uk/
3. https://twitter.com/TheFCA
4. https://www.linkedin.com/company/financi...

Freedom of Information Appeals, The Financial Conduct Authority

3 Attachments

Our Ref: FOI6689

 

Dear Mr Isaac

 

Freedom of Information: Right to know request

 

I refer to my email dated 6 December 2019.  I am writing to inform you
that we have not yet reached a decision regarding your request for an
internal review of the FCA’s response to your information request with the
above reference, made under the Freedom of Information Act 2000.

 

We are still considering this matter and hope to be in a position to
respond to you by Friday 18 January 2020, although should we be able to
contact you sooner we will do so.

 

Thanking you for your patience.

 

Yours sincerely

 

 

Information Disclosure Team / Cyber and Information Resilience Department
/ Operations

[1]Description: cid:image001.png@01D2A7C9.64DDD390

12 Endeavour Square

London

E20 1JN

 

Tel:    +44 (0)20 7066 1000

[2]www.fca.org.uk

 

Follow us:

 

[3]Description: https://g.twimg.com/Twitter_logo_blue.pn...
image003

 

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

References

Visible links
2. http://www.fca.org.uk/
3. https://twitter.com/TheFCA
4. https://www.linkedin.com/company/financi...

Dear Freedom of Information Appeals,

Thank you for your latest correspondence.

I refer to my previous reply in which I stated it was completely unacceptable for the process to have taken so long as still remain unsatisfied. I have given ample opportunity for this to be resolved and now the FCA is failing to meet its own deadline for a resolution.

I expect this matter to be concluded shortly and, in the meantime, I am left with no alternative but to now elevate this matter with a formal complaint to the ICO. That is being initiated today and has been an absolute last resort.

Yours sincerely,

Darren Isaac

Freedom of Information Appeals, The Financial Conduct Authority

1 Attachment

Our Ref: FOI6689
 
Dear Mr Isaac
 
Freedom of Information: Right to know request
 
Thank you for your email below.  Please accept our sincere apologies for
the delay in responding to your request. This is because we are currently
experiencing a very high volume of incoming requests and are having to
prioritise them in date order.
 
We will endeavour to send you a response by Friday 17 January 2020 or
before this date if possible.
 
In the meantime, we thank you for your understanding and patience.
 
Yours sincerely,
 
Information Disclosure Team / Cyber and Information Resilience Department
/ Operations
12 Endeavour Square
Stratford
London
E20 1JN
[1]www.fca.org.uk
 
 
 
 

show quoted sections

Freedom of Information Appeals, The Financial Conduct Authority

3 Attachments

Our Ref: FOI6689

 

Dear Mr Isaac

 

Freedom of Information: Right to know request

 

l refer to our email of 8 January 2020 and confirm that we are currently
finalising our response to your request which we hope to be able to
provide to you in the next few days.

 

I appreciate that you had hoped for an early response and would ask that
you please accept our sincere apologies for the delays that have occurred
in responding to you. This has been due to our currently experiencing a
very high volume of incoming requests and having to prioritise them in
date order.

 

Many thanks for your continuing patience and understanding.

 

Yours sincerely,

 

Information Disclosure Team / Cyber and Information Resilience Department
/ Operations

[1]Description: cid:image001.png@01D2A7C9.64DDD390

12 Endeavour Square

London

E20 1JN

 

Tel:    +44 (0)20 7066 1000

[2]www.fca.org.uk

 

Follow us:

 

[3]Description: https://g.twimg.com/Twitter_logo_blue.pn...
image003

 

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
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Dear Freedom of Information Appeals,

Thank you for the update.

Unfortunately, I must advise that due to the time this has taken (approximately 9 months) I have had no alternative but to raise a complaint with the ICO and this is in progress.

In the event the FCA satisfies my request, I would be prepared to considering withdrawing the complaint but it is presently underway.

I hope the matter can be adequately resolved in your final response.

Yours sincerely,

Darren Isaac

Freedom of Information Appeals, The Financial Conduct Authority

5 Attachments

Our Ref: FOI6689

 

Dear Mr Isaac

 

Freedom of Information: Right to know request

 

I refer to your e-mail dated 5 November 2019 asking the Financial Conduct
Authority (“FCA”) to review its decision in response to the information
you requested under the Freedom of Information Act 2000, with the above
reference.  Please find attached the outcome of the FCA's review.

 

Please also accept our sincere apologies for the time it has taken to
complete this review.   

 

Yours sincerely

 

Information Disclosure Team / Cyber and Information Resilience Department
/ Operations

[1]Description: cid:image001.png@01D2A7C9.64DDD390

12 Endeavour Square

London

E20 1JN

 

Tel:    +44 (0)20 7066 1000

[2]www.fca.org.uk

 

Follow us:

 

[3]Description: https://g.twimg.com/Twitter_logo_blue.pn...
image003

 

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in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

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Dear Freedom of Information Appeals,

Thank you for your correspondence dated 24th January 2020 in which, to summarise, you have refused my request to supply any stored email data on the basis the searches for this would take too long.

Perhaps you can explain then why you have a commercial partner readily selling this information who has recently sent the following communication out about "the FCA's latest list data" from "The FAC register experts". See below.

This is totally at odds with what is being claimed by the FCA and seems to indicated deliberate obstruction due to commercial interests.

I welcome your explanation to this which is now being passed on to the ICO.

Yours sincerely,

Darren Isaac

The FCA Register Post SM&CR

Dear [x],

The Senior Manager & Certification Regime became effective on 9th December 2019 and we have now received the first cut of FCA Register data which reflects the changes.

So what has changed and what has stayed the same?
CF30’s haven’t all disappeared! It is still in use for individuals in Appointed Representative firms. There are still 14,073 people on the register with the CF30 Customer Advisor controlled Function.
To confuse things further 2,199 people now have both SMF and CF functions.
44,002 people now have SMF function(s) but have lost their CFs.
54,747 firm/individual combinations for people who were CF30 in Directly Authorised firms have, however, been removed and are no longer on the FCA Website or the Extract.
Non-Executive Directors (CF2) have also been removed.
As you are probably aware, the FCA are developing the Directory to sit alongside the Register which will contain people carrying out CF30 equivalent activities as well as lots of new people such as mortgage brokers and middle management staff. So we will start getting an even broader picture of who is working in the industry.
In the meantime, a new Status for Individuals of ‘Regulatory approval no longer required’ has been created by the FCA. This is now the status both for people who have been removed from the register as a result of SM&CR, and also for those that have left the industry 1, 5, 10 or even 15 years ago.
Clearly someone who was CF30 on Friday 6th December 2019 is almost certainly going to still be advising clients on Monday 9th December 2019, while someone who left the register 5 years ago is highly unlikely to suddenly start advising again on that Monday.
We have therefore decided to continue with the ‘Inactive’ status for people who have been de-authorised other than at SM&CR date, and have brought all the CF30’s that were de-authorised at CM&CR back into our data environment. That is over 54,000 advisers that are no longer provided to anyone that takes the data from the FCA.
We have added a marker where someone has lost CF30 status due to SM&CR. Their Controlled Function will now be represented as “CF30 Customer}” to distinguish from those that are still CF30 on the Register (that’s the curly bracket to the left of ‘enter’ on the keyboard).
We have also added a new column to the data to indicate where someone has left the Register as a result of SM&CR. This will be Y where this is the case so you can easily include or exclude them.
We have around 4,000 less individuals post SM&CR than we did prior to it, and these are mostly the NED’s. We have chosen not to bring these back into our data environment because they are not in demand by clients, but if anyone wants a list of NED’s as at 8/12/19 we would be happy to provide it.
A lot of new Senior Management Function (SMF) activities have been created and in addition we can now easily identify people who are responsible for Mortgage Credit Distribution, Insurance Distribution and Insurance Mediation.
The most prevalent functions are shown on the table below:
Function Number of Individuals*
CF30 Customer 84,369
SMF3 Executive Director / SMF3 (AR) Executive Director 37,244
CF1 Director 16,906
SMF17 Money Laundering Reporting Function 13,485
SMF16 Compliance Oversight Function 13,029
Responsible for Insurance Distribution 12,363
SMF27 Partner 8,733
SMF1 Chief Executive 5,784
Responsibility for MCD Intermediation 4,458
CF4 Partner 3,049
SMF8 Credit Union Senior Manager 1,672
SMF9 Chairman 1,607
SMF7 Group Entity Senior Manager 1,103
SMF18 Other Overall Responsibility Function 963
SMF2 Chief Finance Function 933
SMF4 (AR) Partner function 827
SMF24 Chief Operations 730
SMF11 Chair of the Audit Committee 677
SMF10 Chair of the Risk Committee 654
SMF5 Head of Internal Audit 586

* Many individuals have more than one CF/SMF so the table should not be added up to get a total number of individuals

I am sure the number of CF30’s seems very high, so please remember that a lot of them are in segments other than the Retail Advisory market - particularly the Investment/Capital Management segment. We can, of course, tell you every name and where they work for everyone in the table above.

What does this mean for you?
The FCA Data environment just got more complex, and it will get more complex again once the Directory data becomes available in a couple of months.
We are developing our systems to accommodate the Directory data (which is being delivered via API only) so the cost of our products will be going up in April. All clients in contract at that time will continue to receive a lower price and will not be affected as the reduced rate will continue to apply at renewal.
Some of our clients want to know about particular types of people based on specific Controlled Functions so I will be in touch with each of these to see which SMF’s they now want to include in their ‘Relevant Universe’.
We will continue to know about changes to Advisors in AR firms, but for a short period not those in DA firms. Our approach of retaining those advisors that were active the day before SM&CR gives you the best view of the market possible.
Heraclitus apparently said “The only constant in life is change” so our business continues to evolve to make sure you have the most accurate and comprehensive view of the people and firms operating in the Financial Services market.
Please do get in touch if you have any queries about this or any other matter we may be able to help you with.
Yours sincerely,
Andy Marson

Managing Director, Operations
Autus Data Services | The FCA Register Experts

Freedom of Information Appeals, The Financial Conduct Authority

4 Attachments

Our Ref: FOI6689

 

Dear Mr Isaac

 

Freedom of Information: Right to know request

 

I refer to your e-mail dated 27 January 2020 asking the Financial Conduct
Authority (“FCA”) to comment on your understanding that a third party is
selling information to which we have previously cited section 12 (Cost of
compliance exceeds appropriate limit) of the Freedom of Information Act.

 

We apologise for the delay in responding to you however please now find
attached our reply.  

 

For ease of reference please find below the hyperlink included within our
reply:

 

[1]https://www.fca.org.uk/firms/financial-s....

 

Yours sincerely

 

Information Disclosure Team / Cyber and Information Resilience Department
/ Operations

[2]Description: cid:image001.png@01D2A7C9.64DDD390

12 Endeavour Square

London

E20 1JN

 

Tel:    +44 (0)20 7066 1000

[3]www.fca.org.uk

 

Follow us:

 

[4]Description: https://g.twimg.com/Twitter_logo_blue.pn...
image003

 

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

References

Visible links
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3. http://www.fca.org.uk/
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We don't know whether the most recent response to this request contains information or not – if you are Darren Isaac please sign in and let everyone know.